submatix EC approval organisation

**fireman** · 2nd March 2007, 15:07

Sorry, what is the legal issue in a nutshell?

**PhilSiswick** · 2nd March 2007, 15:08

Quote: (Originally Posted by fireman)

Sorry, what is the legal issue in a nutshell?

PM Sent

AD_ward9 · 2nd March 2007, 15:12

Quote: (Originally Posted by PhilSiswick)

I understand that for all of you in the good old US of A, this is probably very funny. For those of us in the EU, this is more important. There is a very significant legal issue under discussion here, so please leave us to it.

Everyone knows the arguments about the KISS and the mortality rate on pretty much the only completely CE certified unit. Stop banging on about those.

Cheers,

Thanks Phil.

I will go further there is not a single unit that complies fully with the CE Standard. That is why some deaths occur, IMHO.

This issue is a very important legal point.

There is confusion amongst some Notified Bodies about what is required, but the law is quite clear.

EN14143:2003 is on the European list of PPE Standards. Only an accredited Notified Body to PPE that is certified for Respiritory Equipment including diving equipment, can act for a company making rebreathers and issue a certification.

EN14143:2003 requires compliance with EN61508. The only company accredited to certify either the equipment or process used to design the equipment complies with EN61508, is SIRA Certification. SIRA have not certified any rebreather. I can say with complete confidence that no rebreather meets the safety requirements required by EN61508, and also that none on the market at present could possibly meet those requirements.

There seems to be two levels of "self deception".
1. Companies that issue EN14143:2003 compliance certificates when they have no authorisation to do so whatsoever. Such as the Submatrix certificate. Those companies are acting unlawfully, and possibly fraudulently.

2. Companies who are accredited to issue EN14143:2003 compliance certificates but do so where there is no EN61508 compliance, and patently no compliance. Those companies are acting incompetently.

To help dispell the mystique that surrounds this, we will publish our entire compliance reports as soon as we can get an auditor to finish auditing them.

Alex

**PhilSiswick** · 2nd March 2007, 15:13

Quote: (Originally Posted by AD_ward9)

Thanks Phil.

I will go further there is not a single unit that complies fully with the CE Standard. That is why deaths occur, IMHO.

This issue is a very important legal point.

There is confusion amongst some Notified Bodies about what is required, but the law is quite clear.

EN14143:2003 is on the European list of PPE Standards. Only an accredited Notified Body to PPE that is certified for Respiritory Equipment including diving equipment, can act for a company making rebreathers and issue a certification.

EN14143:2003 requires compliance with EN61508. The only company accredited to certify either the equipment or process used to design the equipment, is SIRA Certification. SIRA have not certified any rebreather. I can say with complete confidence that no rebreather meets the safety requirements required by EN61508, and also that none on the market at present could possibly meet those requirements.

There seems to be two levels of "self deception".
1. Companies that issue EN14143:2003 compliance certificates when they have no authorisation to do so whatsoever. Such as the Submatrix certificate. Those companies are acting unlawfully, and possibly fraudulently.

2. Companies that issue EN14143:2003 compliance certificates where there is no EN61508 compliance, and patently no compliance. Those companies are acting incompetently.

To help dispell the mystique that surrounds this, we will publish our entire compliance reports as soon as we can get an auditor to finish auditing them.

Alex

Alex,

Thanks for the summary.

Cheers,

Ben Field · 2nd March 2007, 15:19

Quote: (Originally Posted by PhilSiswick)

Alex, Thanks for the summary.
Cheers,

Agreed.

If this wasn't so important it would be funny....

malouin · 2nd March 2007, 15:41

Sorry but im not a specialist but the real question is: Is it dangerous to dive with a Submatix CCr to 80m or deeper ?

Is it realy possible to dive legaly with this machine in France ,

Regards,
Emmanuel

AD_ward9 · 2nd March 2007, 15:56

Quote: (Originally Posted by malouin)

Sorry but im not a specialist but the real question is: Is it dangerous to dive with a Submatix CCr to 80m or deeper ?

Is it realy possible to dive legaly with this machine in France ,

Regards,
Emmanuel

Question 1: Unknown because it has not been tested competently. The answer is probably "Yes, it is dangerous", as it does not comply with the minimum safety requirement in the Standard.

Question 2: It is legal for you to dive with it, but cannot lawfully be sold or be used in work because the Certificate of Compliance is not issued by an accredited body and is incompetent.

Alex

Faceless · 2nd March 2007, 16:10

A creator of Submatix has made a presentation at "Neptune show" in Moscow.
Answering on my question regarding CE approval he claimed that none of current CE approved Submatix moders are containing electronics at all.
I.e. only aSCR or mCCR are CE certified.

AD_ward9 · 2nd March 2007, 16:25

Quote: (Originally Posted by Faceless)

A creator of Submatix has made a presentation at "Neptune show" in Moscow.
Answering on my question regarding CE approval he claimed that none of current CE approved Submatix moders are containing electronics at all.
I.e. only aSCR or mCCR are CE certified.

It still does not comply as the certificate is not issued by an accredited body.

Also the equipment misses certain safety features that are needed to meet EN14143.

A mCCR can't get through the EN14143 tests without a very liberal interpretation, which one would have to get approved by the CEN-SC7 Committee. Not aware of that having been done in this case.

aSCR, again missing certain safety features to meet the standard.

If the thing is claimed to meet the Standard but they just were not aware of the legal requirements, why don't they just publish a link to their Technical File with the Compliance Document? At least then we would know misleading us was just a legal slip up and not intentional.

Alex

paulraymaekers · 3rd March 2007, 09:28

Quote: (Originally Posted by Faceless)

A creator of Submatix has made a presentation at "Neptune show" in Moscow.
Answering on my question regarding CE approval he claimed that none of current CE approved Submatix moders are containing electronics at all.
I.e. only aSCR or mCCR are CE certified.

eeuuhh????
how can you run a mCCR without any electronics ????? no way to know your PPO2 ????

paul

2nd March 2007, 15:07	#61 (permalink)
fireman rEvo combat swimmer Current Rebreather/s: rEvo Other CCR Other Rebreather/s: rEvo Other CCR Join Date: Nov 2006 Location: chicago Posts: 498	Re: submatix EC approval organisation Sorry, what is the legal issue in a nutshell? __________________ Heres to you Capt. Bill Never Forget, and stay safe everyone.
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2nd March 2007, 15:08	#62 (permalink)
PhilSiswick WSKD 0001 Current Rebreather/s: Evolution Other Rebreather/s: Inspiration Vision Join Date: Apr 2006 Location: Oxford, UK Posts: 923	Re: submatix EC approval organisation Quote: (Originally Posted by fireman) Sorry, what is the legal issue in a nutshell? PM Sent __________________ Phil No comment on open circuit... it's an evolutionary dead end not really worth discussing here. Dave Sutton, 2007 I have always felt that the dive I am on is not nearly important as the dives I plan to be on the rest of my life. Tom Rose, 2007 www.hugsac.org.uk
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2nd March 2007, 15:12	#63 (permalink)
AD_ward9 So much more to learn Current Rebreather/s: Other CCR Other Rebreather/s: Other CCR Join Date: Jun 2005 Location: Scotland Posts: 1,732	Re: submatix EC approval organisation Quote: (Originally Posted by PhilSiswick) I understand that for all of you in the good old US of A, this is probably very funny. For those of us in the EU, this is more important. There is a very significant legal issue under discussion here, so please leave us to it. Everyone knows the arguments about the KISS and the mortality rate on pretty much the only completely CE certified unit. Stop banging on about those. Cheers, Thanks Phil. I will go further there is not a single unit that complies fully with the CE Standard. That is why some deaths occur, IMHO. This issue is a very important legal point. There is confusion amongst some Notified Bodies about what is required, but the law is quite clear. EN14143:2003 is on the European list of PPE Standards. Only an accredited Notified Body to PPE that is certified for Respiritory Equipment including diving equipment, can act for a company making rebreathers and issue a certification. EN14143:2003 requires compliance with EN61508. The only company accredited to certify either the equipment or process used to design the equipment complies with EN61508, is SIRA Certification. SIRA have not certified any rebreather. I can say with complete confidence that no rebreather meets the safety requirements required by EN61508, and also that none on the market at present could possibly meet those requirements. There seems to be two levels of "self deception". 1. Companies that issue EN14143:2003 compliance certificates when they have no authorisation to do so whatsoever. Such as the Submatrix certificate. Those companies are acting unlawfully, and possibly fraudulently. 2. Companies who are accredited to issue EN14143:2003 compliance certificates but do so where there is no EN61508 compliance, and patently no compliance. Those companies are acting incompetently. To help dispell the mystique that surrounds this, we will publish our entire compliance reports as soon as we can get an auditor to finish auditing them. Alex Last edited by AD_ward9 : 2nd March 2007 at 15:37. Reason: For precision
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2nd March 2007, 15:13	#64 (permalink)
PhilSiswick WSKD 0001 Current Rebreather/s: Evolution Other Rebreather/s: Inspiration Vision Join Date: Apr 2006 Location: Oxford, UK Posts: 923	Re: submatix EC approval organisation Quote: (Originally Posted by AD_ward9) Thanks Phil. I will go further there is not a single unit that complies fully with the CE Standard. That is why deaths occur, IMHO. This issue is a very important legal point. There is confusion amongst some Notified Bodies about what is required, but the law is quite clear. EN14143:2003 is on the European list of PPE Standards. Only an accredited Notified Body to PPE that is certified for Respiritory Equipment including diving equipment, can act for a company making rebreathers and issue a certification. EN14143:2003 requires compliance with EN61508. The only company accredited to certify either the equipment or process used to design the equipment, is SIRA Certification. SIRA have not certified any rebreather. I can say with complete confidence that no rebreather meets the safety requirements required by EN61508, and also that none on the market at present could possibly meet those requirements. There seems to be two levels of "self deception". 1. Companies that issue EN14143:2003 compliance certificates when they have no authorisation to do so whatsoever. Such as the Submatrix certificate. Those companies are acting unlawfully, and possibly fraudulently. 2. Companies that issue EN14143:2003 compliance certificates where there is no EN61508 compliance, and patently no compliance. Those companies are acting incompetently. To help dispell the mystique that surrounds this, we will publish our entire compliance reports as soon as we can get an auditor to finish auditing them. Alex Alex, Thanks for the summary. Cheers, __________________ Phil No comment on open circuit... it's an evolutionary dead end not really worth discussing here. Dave Sutton, 2007 I have always felt that the dive I am on is not nearly important as the dives I plan to be on the rest of my life. Tom Rose, 2007 www.hugsac.org.uk
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2nd March 2007, 15:19	#65 (permalink)
Ben Field CK+Shearwater Current Rebreather/s: Classic Kiss Other Rebreather/s: Sport Kiss Join Date: Aug 2005 Location: London, England Posts: 1,571	Re: submatix EC approval organisation Quote: (Originally Posted by PhilSiswick) Alex, Thanks for the summary. Cheers, Agreed. If this wasn't so important it would be funny.... __________________ www.hugsac.org.uk Beware Fridge Suck
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2nd March 2007, 15:41	#66 (permalink)
malouin New Member Current Rebreather/s: Inspiration Vision Other Rebreather/s: Join Date: Feb 2007 Location: Saint Malo (France) Posts: 27	Re: submatix EC approval organisation Sorry but im not a specialist but the real question is: Is it dangerous to dive with a Submatix CCr to 80m or deeper ? Is it realy possible to dive legaly with this machine in France , Regards, Emmanuel
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2nd March 2007, 15:56	#67 (permalink)
AD_ward9 So much more to learn Current Rebreather/s: Other CCR Other Rebreather/s: Other CCR Join Date: Jun 2005 Location: Scotland Posts: 1,732	Re: submatix EC approval organisation Quote: (Originally Posted by malouin) Sorry but im not a specialist but the real question is: Is it dangerous to dive with a Submatix CCr to 80m or deeper ? Is it realy possible to dive legaly with this machine in France , Regards, Emmanuel Question 1: Unknown because it has not been tested competently. The answer is probably "Yes, it is dangerous", as it does not comply with the minimum safety requirement in the Standard. Question 2: It is legal for you to dive with it, but cannot lawfully be sold or be used in work because the Certificate of Compliance is not issued by an accredited body and is incompetent. Alex Last edited by AD_ward9 : 2nd March 2007 at 16:00.
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2nd March 2007, 16:10	#68 (permalink)
Faceless alone lurking in wrecks Current Rebreather/s: Not Bought Yet Other Rebreather/s: Not Bought Yet Join Date: May 2006 Location: France, Montpellier Posts: 92	Re: submatix EC approval organisation A creator of Submatix has made a presentation at "Neptune show" in Moscow. Answering on my question regarding CE approval he claimed that none of current CE approved Submatix moders are containing electronics at all. I.e. only aSCR or mCCR are CE certified. __________________ Peoples risk perception is almost always focused on the most dramatic rather than the most probable. (c) Gordon Smith
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2nd March 2007, 16:25	#69 (permalink)
AD_ward9 So much more to learn Current Rebreather/s: Other CCR Other Rebreather/s: Other CCR Join Date: Jun 2005 Location: Scotland Posts: 1,732	Re: submatix EC approval organisation Quote: (Originally Posted by Faceless) A creator of Submatix has made a presentation at "Neptune show" in Moscow. Answering on my question regarding CE approval he claimed that none of current CE approved Submatix moders are containing electronics at all. I.e. only aSCR or mCCR are CE certified. It still does not comply as the certificate is not issued by an accredited body. Also the equipment misses certain safety features that are needed to meet EN14143. A mCCR can't get through the EN14143 tests without a very liberal interpretation, which one would have to get approved by the CEN-SC7 Committee. Not aware of that having been done in this case. aSCR, again missing certain safety features to meet the standard. If the thing is claimed to meet the Standard but they just were not aware of the legal requirements, why don't they just publish a link to their Technical File with the Compliance Document? At least then we would know misleading us was just a legal slip up and not intentional. Alex Last edited by AD_ward9 : 2nd March 2007 at 16:46. Reason: Missed half of one important word. The word "out", as in "without".
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3rd March 2007, 09:28	#70 (permalink)
paulraymaekers rEvo's daddy Current Rebreather/s: rEvo Other CCR Home Build Other Rebreather/s: rEvo Other CCR Home Build Join Date: May 2005 Location: belgium Posts: 1,439	Re: submatix EC approval organisation Quote: (Originally Posted by Faceless) A creator of Submatix has made a presentation at "Neptune show" in Moscow. Answering on my question regarding CE approval he claimed that none of current CE approved Submatix moders are containing electronics at all. I.e. only aSCR or mCCR are CE certified. eeuuhh???? how can you run a mCCR without any electronics ????? no way to know your PPO2 ???? paul __________________ www.rEvo-rebreathers.com .... the earth is flat, Elvis is alive, and radial scrubbers give longer dwell time than axials...
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